Submission - Independent Pilots Association

117.19(f)(1)(modified) The pilot in command and certificate holder may extenda flight duty period beyond the scheduled flight duty period up to 3 2 hours.117.19(f)(2)(modified) An extension in the scheduled flight duty periodexceeding 30 minutes may occur only once in any 168 consecutive hour period.*As an administrative matter, we have pointed out in our clarifyingquestions on the docket that Table C as published in the NPRM has anincorrect heading. The table heading needs to match Table B and the“Time of Start” should include home base or acclimated local time.The NPRM proposed chart in Table C is based on the TNO Report. Upon a furtherreview of the TNO Report, we believe the proposed Table C was oversimplified in tworegards. The first was that many of the values were oversimplified following a roundingprocess that does not adequately represent the actual calculations used in the ARCprocess. The second oversimplification is the use of a standard 30-minute reduction fora nonacclimated crewmember. The end result is an improper application of anonacclimated penalty for the operation planned. Additionally, just as is the case withthe acclimated discussion, a table that reflects the true values is better suited toaccurately reflect the appropriate reduction for the crewmember not being acclimated. Intoday’s world with the prevalence of electronic interaction with schedules, there is littleneed to round values to a whole or half hour.Additionally, the TNO Report was intended for single segment operation only and theaddition of more than one additional segment would stray too far from the science onwhich the charts were developed. Multi-leg augmentation should only be allowed whenno crew change is possible. Multi-leg augmentation should never be used solely for thepurpose of extending a flight duty period. Augmented flights must not be mixed withnon-augmented flights in the same flight duty period.The proposed regulation 117.19 (c)(3) provides for a 2-hour consecutive sleepopportunity for the flight crewmember manipulating the controls on landing. That sleepopportunity should be mandated for both required crewmembers during approach andlanding. Both crewmembers manipulate the controls, i.e., the pilot monitoring normallyoperates flaps, landing gear, and radios and performs monitoring so he must be equallyalert. Much emphasis has been placed on the concept of crew resource management(CRM) and pilot monitoring duties. 19 Also, there are circumstances such as Category IIIapproaches where the pilot monitoring might actually be the pilot landing. To depriveany of the operating flightcrew members an in-flight rest opportunity would not help19 Robert Sumwalt, Ronald Thomas and Key Dismukes, Enhancing Flightcrew MonitoringSkills Can Increase Flight Safety, 55 th Air Safety Seminar, (Nov. 2002).22